Court Overturns Murder Convictions for Three Santa Clara Sheriff’s Deputies

An appeals court has overturned the murder convictions of three former Santa Clara sheriff’s deputies involved in the 2015 beating death of mentally ill inmate Michael Tyree. The decision is a result of SB 1437 (Skinner), signed by Gov. Jerry Brown in 2018, which raised the threshold for some felony murder convictions in California.

Under prior law, a person could be found guilty of murder as long as a person was killed – whether intentionally or unintentionally – during the commission of a serious felony. That was the case even if the person did not commit the killing themselves, as long as they were a participant in the underlying crime.

Under SB 1437, a person can only be convicted of felony murder if the killing occurred at their hands, if they acted with intent to kill, if they were a major participant in the crime, or if the victim was a police officer. Under SB 1437 – which was retroactive – each of the defendants in the Tyree case would need to be evaluated on these bases separately. That did not happen at trial because the prosecution was operating on the now invalidated natural and probable consequences theory.  That makes the jury instruction in the trial retroactively improper.

The ruling doesn’t necessarily mean the defendants in the Tyree case walk, but it does mean they need to be retried.

"The prosecution may elect to retry defendants on a valid theory or theories of homicide with a properly instructed jury," wrote Associate Justice Thomas M.Goethals with the 4th District Court of Appeals. The District Attorney's Office has not said whether it will refile the case. 

The killing of Tyree cast a shadow over Santa Clara seven years ago and led to major changes within the sheriff’s department. The impact of this decision will be felt throughout California’s justice system.


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